E-Mail generated [Aug 2 2017]

0305-EX-CN-2017 Correspondence

Swarm Technologies, Inc.

2017-08-02ELS_196067

To: Craig Scheffler
E-Mail: craig@swarm-technologies.com
From: Doug Young
Date: August 02, 2017

Subject: Request for Info - File # 0305-EX-CN-2017
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Message:

Please address the FCC’s International Bureau/Satellite Divisions concerns below:

ODAR comments/issues:

Please provide the full dimensions of the antennae (thickness, length, width).

Do we understand correctly that the DAS collision analysis was completed for a single satellite, and with
an area-to-mass figure based on the satellite body, excluding the antenna? If not, please describe in
more detail the analysis undertaken, and address whether the satellites’ largest dimension has been
adequately accounted for in the analysis.

Please provide an analysis or estimate of the average A/M of the satellites if tumbling.

Please provide an estimate of the altitude at which satellite attitude stability is expected to degrade
substantially, and/or cease.

Please address whether skin friction effects on the antenna can be expected to reduce orbital lifetime.

Please address whether “skin friction” effects on the antenna can be expected to reduce attitude stability.

As launched, will the satellites have a transmission schedule, or is the initiation of satellite transmissions
dependent on an initial schedule uploaded via earth station transmissions? Will initial satellite acquisition
be solely dependent on radar or other observation data?

Do the Haystack observations require special funding or cooperative research arrangements, or are the
observations within the standard scope of Haystack activities?

Other than a GPS receiver, are there any other measurement devices/sensors on the spacecraft?

U.S. Table of frequency allocation comments:

137.825-138 MHz
Mobile-satellite (space-to-Earth) US319 US320
RR FN 5.208

RR FN 5.208: The use of the band 137-138 MHz by the mobile-satellite service is subject to coordination
under No. 9.11A.

FN US320: The use of the bands 137-138 MHz, 148-150.05 MHz, 399.9-400.05 MHz, and 400.15-401
MHz by the mobile-satellite service is limited to non-voice, non-geostationary satellite systems and may
include satellite links between land earth stations at fixed locations.

Please note that the MSS allocation in the 137-138 MHz band only allows downlink operations; applicant
is proposing to operate in the 137-138 MHz band in the uplink direction which is not in accordance with
the Radio Regulation. The applicant has not provided an electromagnetic compatibility (EMC) analysis to
show that the uplink operations will not cause harmful interference to other downlink earth stations.

Applicant please submit an EMC analysis for the uplink operations to show compatibility other FCC
license stations in the 137-138 MHz band. We note that the applicant has obtained consent from
ORBCOMM. However, applicant must be aware that the downlink operation will required coordination
under No. 9.11A.

Form 442:

For the 137.95 MHz uplink operations, the application has identified earth station as a MOBILE station
class with a radius of operation of 5 km. Applicant please clarify if the uplink earth station is moving while
transmitting or does it operate in a fixed location but is transportable within a 5-km radius. Why is there a
need to move the earth station?

SpaceCap API file:

On the uplink, RX beam:

The box RR 4.4 was NOT checked “Y”; however, this uplink is not in accordance with the ITU RR so this
box will need to be checked “Y”.

On the max peak power, it has a value of 3.4 dBW and min peak power has a value of 2.3 dBW;
however, Form 442 has this power as 1 W = 0 dBW; applicant please review the power levels in both
form and update either form to make the technical parameters consistent.

If the power level changes then the power spectral density value will also need to be updated.

On the associated earth station, the co-polar reference pattern is identified as ND-EARTH (which is
non-direction earth); however, we note that the beamwidth is 90 degrees which is directional; therefore,
we suggest that we remove this ND-EARTH reference and submit the antenna pattern earth station
provided in the application.

On the downlink, TX beam:

Box RR No. 4.4 is not marked “Y” which indicates that the applicant will need to coordinate this frequency
band.

The minimum elevation angle is given as 0 degrees; however, this value should be 5 degrees.

On the max peak power, it has a value of -8.7 dBW and min peak power has a value of -9.8 dBW;
however, Form 442 has this power as 100 mW = -10 dBW; applicant please review the power levels in
both form and update either form to make the technical parameters consistent.

On the associated earth station, the co-polar reference pattern is identified as ND-EARTH (which is
non-direction earth); however, we note that the beamwidth is 90 degrees which is directional; therefore,
we suggest that we remove this ND-EARTH reference and submit the antenna pattern earth station
provided in the application.

Exhibit A document:
On the introductory section, second paragraph, start of the second line, it describes the satellite as
microsatellites; however, these satellites would fall under nano-satellite or femto-satellites depending of
their weight but not microsatellites.

Document Created: 2017-08-02 10:42:40
Document Modified: 2017-08-02 10:42:40

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